Privacy Policy

We are Trader Corporation (“Trader”), the owner and operator of the insights.trader.ca website (the “Website”). In order to give you a personalized experience when you use our website, and in order to provide our services, we collect some information about you. We understand that your privacy is important, and we are committed to being open with you about the information that we collect, and how and why we use it.

By using the Website, you consent to the collection, use, storageand disclosure of this information as described in this Privacy Policy.If you do not, or can not consent to these terms, you cannot use the Website

If you have any questions or concerns related to this Privacy Policy or your personal information, please contact our Privacy Officer at privacy.officer@trader.ca. We welcome suggestions as to how we could improve our privacy policy and practices — we may not be able to implement every suggestion, but we care about your privacy and we welcome your comments.

The “Website” means the Trader Carology Insights website accessible at insights.trader.ca and any associated or co-branded features, applications, services or websites provided to you by Trader.

The “Policy”, or the “Privacy Policy” means this privacy policy, including amendments, modifications, and additions.

2. CATEGORIES OF INFORMATION

Some information that we may collect, like your email address or your IP address, might enable someone to identify you personally. We call this type of information “Personally Identifying Information,” and we use our best efforts to maintain the confidentiality of this type of information. This category does not include any personally identifying information that you choose to post in publicly accessible areas of the Website.

We may collect other information, such as details of your browsing patterns on the website, data contained in web “cookies”, a history of links that you have clicked on, coarse geographic and location data (eg: what town or city you are connecting from), or any other data that we store and use to determine your interests and customize your user experience. We recognize that disclosure of such information might compromise your privacy if it was accompanied by Personally Identifying Information, thereby allowing someone to associate this information with you. However, if such information were disclosed without any accompanying Personally Identifying Information, it would not directly reveal anything about you personally. We call this type of information “Demographic Information,” and we may share this type of information with third parties, but never accompanied by Personally Identifying Information (except where we may be required or compelled to do so, for example in response to a court order, or as required in order to provide services to you.) Collection and use of each of these categories of information is crucial to our business and operations, and to our ability to provide services to you. We collect and use this information in order to establish, maintain and manage our relationship with you, to communicate with you, to personalize your user experience on the Website, to provide you with advertising and content tailored to your interests, and to provide services to you. We may be required to use the information we collect to enforce our legal rights, or to defend against claims or other legal action. Collection of this information also allows us to assess and improve the services which we provide, and to analyze user habits and market trends.

3. DEFINITION OF PERSONAL INFORMATION

For the purposes of this Policy, “Personal Information” means:

1:Personally Identifying Information (not including identifying information that you choose to post in publicly accessible areas of the Website or in your user profile); and

2:Sets or collections of Demographic Information (and/or other information which does not itself identify you personally), associated with Personally Identifying Information in such a way that the individual to whom the information relates could readily and easily be identified.

4. USE AND DISCLOSURE OF PERSONAL INFORMATION

You permit us to collect, use and disclose your Personal Information as described in this Policy. With your consent, we may also collect, use or disclose your Personal Information for other purposes. Such consent may be express, deemed, or implied, as may be reasonable under the circumstances — for example, your consent will be implied where you submit Personal Information in circumstances where it should be clear to you that the information must be used, collected, or disclosed in order to provide a service that you have requested. We may collect, use, maintain or disclose your Personal Information without your knowledge or consent where permitted or required by applicable law.

Your Personal Information may also be used and disclosed, if required, to enable us to comply with applicable legal and regulatory requirements. For example, we may be required to disclose some or all of your Personal Information in order to comply with a court order or subpoena. Where reasonably possible, and provided we are not precluded from doing so, we will make a reasonable effort to inform you if we are ever required to disclose your Personal Information pursuant to a court order.

We may use contact information that you provide to contact you about the Website and the services we provide, or otherwise to maintain our relationship with you. We collect customers’ financial information (such as account or credit card numbers) to bill users for products and services, but we retain this information only as required to process the transaction and for as long as may be required by law. Trader’s online surveys may ask visitors for contact information (such as email addresses) and demographic information (such as postal code, age, or income level). Trader uses contact data from our surveys to send users information about our products and services. Users may opt-out of receiving future mailings (see the Opt-Out section below).

Trader may use customer information for additional purposes that may be identified at or before the time that the information is collected. Trader also uses information from customers for accounting and transaction completion purposes.

5. PASSWORDS

We do not store your password in our databases. Instead, we store a unique “cryptographic hash” generated from your password. Each time you login, we generate a cryptographic hash from the password you enter, and compare it to the hash stored in our database. If they match, we know you entered the right password.

It is not feasible to determine your password from the cryptographic hash that we store. Even we don’t know what your password is.

6. DATA TRACKING AND USE OF COOKIES, WEB BEACONS OR SIMILAR TECHNOLOGIES

To collect certain information, we may use a browser feature known as a “cookie” or a similar technology such a Web beacon or a tracer tag. Cookies are small files placed on your hard drive that assist us in providing you with a customized browsing experience. A Web beacon or tracer tag is an object embedded in a Web page, often working in conjunction with a cookie, which unobtrusively monitors the behavior of a user on the Web page so that we can understand how you use our website in order to improve the experience.

We use cookies, web beacons, tracer tags and similar technologies to better understand how you use our websites and to improve your experience. For example, a cookie may recall a set of preferences you have set for our website. Cookies are also used to measure the performance of the Website including number of page visits, duration of visits and click-throughs and to direct you to relevant advertisements to third-party websites. These activities are invisible to you, and are generally intended to improve your internet surfing convenience.

The “help” section of the toolbar on most browsers will inform you on how to prevent your browser from accepting new cookies, Web beacons, tracer tags and similar technologies, how to have the browser notify you upon the receipt of a new cookie, Web beacon, tracer tag or similar technology or how to disable the use of cookies, Web beacons and similar technologies completely, as our Web sites have been designed to take advantage of the use of cookies, Web beacons and similar technologies. Should you configure your browser to decline their use, certain features of our Web sites may not function correctly and you may be required to renter any user IDs and passwords more frequently. Tracer tags include the Apple Advertising Identifier (IDFA) and the Google Advertising ID as part of the Google Play Services SDK, both of which attribute app installations to previously served advertisements. You may manage how your mobile device and mobile browser share location information with TRADER, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

We may place advertising or other links on our Website that originate from outside advertisers. If you view these ads, the advertisers may assign a cookie. TRADER does not control these cookies, nor is TRADER responsible for any marketing or other use of your name by these advertisers.

7. WHO CAN ACCESS YOUR PERSONAL INFORMATION

Your Personal Information may be accessible to our employees, contractors, consultants, service providers, and such other parties who require this information to assist us with establishing, maintaining and managing our business relationship with you. This may include third parties engaged to provide services to us (including any parties working with us to provide services to you).

We may disclose your Personal Information to sellers of vehicles on our Website if you ask us to do so, or consent to us doing so. For example, when you submit your personal information on our Website for the purposes of obtaining additional information about a vehicle from the seller, we will provide this information to the seller.

Your Personal Information may be disclosed or transferred in the event of a change in ownership of Trader, or a grant of an interest in Trader, in part or in whole, through any form of business acquisition, merger, joint venture or otherwise. Any party acquiring such an interest in Trader may be granted access to your Personal Information pursuant to terms governing collection, use and disclosure consistent with those set out in this Policy.

8. WE VALUE YOUR CONSENT

It is important to us that we obtain your consent whenever we collect, use, maintain or disclose your Personal Information. You may, at any time, delete your user account here. Your user account information will be maintained for 30 days after you deactivate your account, in case you choose to reactivate the account. Then, (subject to any legal requirement for us to retain these records), your Personally Identifying information will be deleted. We may store anonymized Demographic Information indefinitely.

9. STORAGE OF YOUR PERSONAL INFORMATION

We have data security policies and practices in place, and use our best efforts to safeguard your Personal Information from unauthorized access, use or disclosure. However, we cannot be held liable in the event of unauthorized access to or inadvertent disclosure of any Personal Information.

10. DATA COLLECTION BY THIRD PARTIES

While using the Website, your computer may connect to third-party servers which are not under our control. This may happen, for example, when content hosted on a third-party server is embedded inline in a page on the Website, or if you leave the Website to view linked content. These third parties may collect information about you. We have no control over how they collect, use, or disclose that information. In order to provide services to you, we may engage third party service providers. We may share your personal information with our third party service providers. Third party service providers may have privacy policies and information gathering, storage, and disclosure procedures that differ from those set out herein.

You recognize that during the course of your connection to, or use of the Website, as a result of disclosure to third parties as outlined above, or as a consequence of the network connections used to connect to the Website or any related servers or computer networks, any data transmitted may be transmitted to jurisdictions outside of Canada, and may therefore be subject to the laws of those other jurisdictions, which may differ from the laws of Canada.

We adhere to/comply with the Digital Advertising Alliance of Canada’s (DAAC) Self-Regulatory Principles for Online Behavioral Advertising. You can learn more about the program by visiting the DAAC’s website here http://youradchoices.ca/.

11. OUR PRIVACY OFFICER

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:
Privacy Officer
3555 Gilmore Way, Suite #1 West
Burnaby, BC
V5G 0B3
Email: privacy.officer@trader.ca

Inquiries related to this Policy or concerns relating to the collection, disclosure, accuracy, use or retention of information relating to you should be directed to the Privacy Officer. Our Privacy Officer also welcomes comments and suggestions for improvement to this Privacy Policy and to our privacy practices. We may not be able to implement every suggestion, but we are interested and we are listening.

12. OPTING OUT and CORRECTIONS POLICY

When appropriate, users of the Website are given the opportunity to (i) opt-out of receiving communications from us, (ii) remove their information from our database, or (iii) elect to no longer receive services from us. If you wish to opt-out of receiving further communications, please contact Trader’s privacy officer (the “Privacy Officer”) using the contact information provided above. Users of this Website may contact the Privacy Officer to modify or correct any of their personal information that is under our control. An individual may also direct a written complaint regarding compliance with this Privacy Statement to the Privacy Officer and, within a reasonable time upon receiving the written complaint, the Privacy Officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, the Privacy Officer will inform the complainant whether the complaint will be allowed or denied. If the Privacy Officer considers the complaint to be well founded, Trader will take appropriate measures to address the complaint.

13. REVISIONS TO, AND INTERPRETATIONS OF THE POLICY

We may amend this Policy from time to time by posting an amended version of this Policy on our website at autoTRADER.ca. Any amendments will be effective from the date on which they are posted. By continuing to use the Website after these amendments are posted, you agree to these amendments. This Policy has a limited scope and application, as set out herein and in applicable legislation. This Policy does not create or confer upon any individual any rights, or impose upon us any obligations beyond, or in addition to, those rights or obligations imposed by applicable privacy laws in effect in the Province of Ontario. If in a specific case, any inconsistency between this Privacy Policy and applicable privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws. Any disputes arising in connection with this Policy or in connection with our use, collection or disclosure of any Personal Information shall be governed by the laws of Ontario (and the laws of Canada applicable therein). Any such disputes shall be heard at the Courts in Toronto, Ontario.